Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The AAR held that the Applicant is not entitled to input tax credit for GST paid on fire-fighting systems and public-health equipment installed as part of a new factory. The installations were characterized as permanently affixed to immovable property and thus not "plant and machinery," bringing the supply within the embargoes of s.17(5)(c) and, alternatively, s.17(5)(d) of the CGST/TNGST Act, 2017; GST attributable to the composite works contract is therefore non-creditable. Because ITC denial on the specific contract is dispositive, the AAR declined to adjudicate the ancillary question on the timing for availing ITC against supplier "advance component" invoices.
The AAR held that the Applicant is not entitled to input tax credit for GST paid on fire-fighting systems and public-health equipment installed as part of a new factory. The installations were characterized as permanently affixed to immovable property and thus not "plant and machinery," bringing the supply within the embargoes of s.17(5)(c) and, alternatively, s.17(5)(d) of the CGST/TNGST Act, 2017; GST attributable to the composite works contract is therefore non-creditable. Because ITC denial on the specific contract is dispositive, the AAR declined to adjudicate the ancillary question on the timing for availing ITC against supplier "advance component" invoices.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
